Only Pay Your Taxes First

IRS gets summary J sustaining NITLs for two years at issue, although Judge Albert G (“Scholar Al”) Lauber tells Ronald Sylvester Sullivan, 2019 T. C. Memo. 153, filed 11/19/19, that he’s free at any time to file an OIC, or propose an IA, if he files his nine (count ‘em, nine) missing tax returns and proffers the requisite financial information. See 2019 T. C. Memo. 153, at p. 12.

Ron S.S. did none of the above in support of his CDP. He came to IRS’ attention only because of third-party reporting for two of said years, leading to unpetitioned SNODs.

To explain both why I posted this routine Memo., and why I have given such a mundane post this headline, let me quote only the following.

“Petitioner is a clinical professor of law at Harvard Law School and the faculty director of the Harvard Trial Advocacy Workshop and the Harvard Criminal Justice Institute.” 2019 T. C. Memo. 153, at p. 2.